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EXHIBIT 8.01
[SIDLEY & AUSTIN LETTERHEAD]
August 7, 2000
Campbell & Company, Inc.
General Partner of
Campbell Strategic Allocation Fund, L.P.
210 West Pennsylvania Avenue
Baltimore, Maryland 21204
Re: Registration Statement on Form S-1
Dear Sir or Madam:
We have acted as your counsel in connection with the preparation and
filing with the Securities and Exchange Commission (the "Commission") under the
Securities Act of 1933, as amended (the "Act"), of the Registration Statement on
Form S-1 on or about August 7, 2000 (the "Registration Statement"), relating to
Units of Limited Partnership Interest ("Units") of Campbell Strategic Allocation
Fund, L.P. (the "Fund"), a limited partnership organized under the Delaware
Revised Uniform Limited Partnership Act.
We have reviewed such data, documents, questions of law and fact and
other matters as we have deemed pertinent for the purpose of this opinion. Based
upon the foregoing, we hereby confirm our opinion expressed under the caption
"Federal Income Tax Aspects" in the Prospectus (the "Prospectus") constituting a
part of the Registration Statement that the Fund will be taxed as a partnership
for federal income tax purposes.
We also advise you that in our opinion the description set forth
under the caption "Federal Income Tax Aspects" in the Prospectus correctly
describes (subject to the uncertainties referred to therein) the material
aspects of the federal income tax treatment to a United States individual
taxpayer, as of the date hereof, of an investment in the Fund.
We hereby consent to the filing of this opinion as an Exhibit to the
Registration Statement and all references to our firm included in or made a part
of the Registration Statement. In giving such consent, we do not hereby admit
that we are in the category of persons whose consent is required under Section 7
of the Act or the rules and regulations of the Commission thereunder.
Very truly yours,
SIDLEY & AUSTIN
